•FSA’s New Internal Review Documentation and Tracking System (IRDTS) - FSA has invested in developing IRDTS, a centralized, automated internal control tracking system that allows FSA Management (at all levels) to complete and track internal program audits and reviews. IRDTS allows FSA to incorporate manual-paper based internal control processes in Service Centers into automated processes. The objectives for IRDTS are to improve and enhance oversight capabilities to State and National program managers and formally document review results for program analysis. LFP is scheduled to implement a review in FY22.
•Establishing Annual Compliance Training - Training will be required to create awareness and prepare new and existing employees with the tools to confidently handle situations, protecting Agency’s values, policies, and commitment to applicable compliance laws. Annual training will be established for all FSA employees. The estimated timeframe for establishing this training is by January 30, 2022.
•National LFP training was held in March 18, May 5, June 24, and September 30, 2020 to review policy, common program questions and to discuss root causes of FY 2020 improper payments and policy review associated with those findings. This training was conducted at a more localized level providing smaller sessions to individual states as they triggered for program implementation versus having one national training that may only affect a small portion of the nation at the time of training.
•A monthly LFP policy/software call with state specialists has been established to review program policy and procedures, discuss any questions submitted.  

Commodity Credit Corporation (CCC) Livestock Forage Disaster Program has established a baseline.

The program's current year improper payment and unknown payment rate of 8.0 % has been achieved with a balance of payment integrity risk and controls and represents the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is the tolerable rate.

The agency has the necessary internal controls human capital, and information systems and other infrastructure support to reduce IPs and UPs. The rate was reduced by more than 30% from the previous year. This is a significant accomplishment and a strong indication that the internal controls are working.

National Livestock Forage Disaster Program training is held every year to review policy, common program questions and to discuss root causes of improper payments and policy review associated with those findings. Beginning in 2020, this training was conducted at a more localized level providing smaller sessions to individual states as they triggered for program implementation. The root cause of administrative errors are primarily isolated to failures to follow compliance and acreage reporting policy. An Acreage reporting review is currently underway for Fiscal Year 2022 to help determine the root cause(s) for failure to access data/information and statutory requirements not met errors, including late-filed deficiencies. Farm Service Agency plans to utilize the review results to establish strategies that will improve program processes and establish accountability measures for the remainder of fiscal year 2022 and for fiscal year 2023. Throughout the fiscal year, National, State, and County program managers will continue to evaluate areas where policy needs revising or to be clarified, and additional training is necessary.

Commodity Credit Corporation (CCC) Livestock Forage Disaster Program has NOT established a baseline.

The program's current year improper payment and unknown payment rate of 9.3 % has been achieved with a balance of payment integrity risk and controls and represents the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is the tolerable rate.

The program reported an improper payment error rate of 9.30% for the fiscal year 2022 payment integrity review cycle which is below the agency's 10% tolerable rate.

Farm Service Agency continues to strategically take the necessary steps to strengthen internal controls measures, establish uniform consistency for compliance processes, and improve accountability. Farm Service Agency’s aim is to not only make these improvements at the program specific level but to initiate transformation at the overall arching and broader Agency level.

Farm Service Agency will require key resources to continue its progression towards strengthening internal controls and addressing the inconsistencies with certain programs reporting more than the statutory improper payment threshold in fiscal year 2022.

Human Capital Needs: National and State Office Compliance Resources - To resolve the Agency’s noncompliance issues in a timely manner, strengthen program integrity and accountability and maintain an ongoing compliance oversight strategy, additional compliance staff will be crucial for Farm Service Agency to build a comprehensive and robust compliance program.

Farm Service Agency once had staff positions whose main responsibility involved monitoring and addressing compliance related issues within states known as Farm Service Agency County Operations Reviewer, but these positions were transferred in fiscal year 2019 from Farm Service Agency to the Farm Production and Conservation Business Center, Performance, Accountability and Risk Division during the Farm Production and Conservation Business Center reorganization. This transfer caused a hardship on Farm Service Agency’s internal controls program and significant resource and specialized knowledge gaps are still prevalent today, which is contributing to Farm Service Agency’s capacity to timely and adequately address various compliance issues and requirements. Farm Service Agency and Performance, Accountability and Risk Division are evaluating the current set up to seek improvements as it relates to Farm Service Agency program compliance. In addition, Farm Service Agency’s existing staff continues to be stretched with the responsibilities of training new staff, administering Farm Service Agency programs, performing existing County Operations Reviewers duties, and addressing new compliance requirements, all as collateral duties. Farm Service Agency and Performance, Accountability and Risk Division are developing a new work plan to better address this issue and goal by first quarter fiscal year 2023 to define an improved workplan to support compliance review.

Information Systems’ Needs – Farm Service Agency is positioning itself to take preventive measures through automated processes that are built into business systems to reduce errors. Automation improves productivity and enforces procedural compliance; therefore, Farm Service Agency is exploring better approaches to integrate internal controls functions into the implementation of programs, as well as maintenance of an existing program systems. Given these efforts, the Agency is planning to request Congressional funding for enhancing: 1) transactional program systems/software to quickly meet the implementation demands of pandemic, emergency, and disaster programs and 2) interface systems to allow data sharing and eliminate manual/duplicative entries and processes.

Several transactional program systems and software “work arounds” and manual processes still exist that are contributing to the increase of program improper payments. Funding is needed to resolve current deficiencies and build internal controls requirements within these systems.

From an internal controls oversight perspective, Farm Service Agency has invested in the Internal Review Documentation and Tracking System and continues to incorporate manual-paper based program reviews and spot-checks into automated processes within the system. The objectives for Internal Review Documentation and Tracking System are to improve oversight capabilities to State and National program managers, supplement data mining efforts and formally document review results for program analysis and enrichment. This effort is ongoing and is planned through fiscal year 2024.

Other Infrastructures Needs - As part of the Agency’s new integrated compliance plan, the design will incorporate further actions to address meeting program reduction targets, including but not limited to: 1) changing the current sampling methodology to using better sound statistical, survey, and data collection methodologies that elevate past issues of “oversampling” and inefficient use of resources, while also ensuring the program dollars are delivered to all producers who are legally entitled to them; 2) utilizing a risk-based approach, where program risks and risk tolerances are identified to allow the right internal controls to be put in place, establish program metrics that gages the success of meeting objectives and need for improvements; 3) integrating a more proactive use of data mining to identify program key performance indicators, anomalies, fraud, waste, and abuse; and 4) performing a validity reassessment of current program oversight processes, such as oversight checklists, redelegation of authorities for approvals, etc.

These actions will also assist in capturing program impacts to targeted arenas of the historically underserved groups and determining where increased efforts are needed to improve accessibility to Farm Service Agency programs and services. For example, implementing routine sampling of denied applications on historically underserved groups to verify if approval and disapproval decisions are being made accurately.

Farm Service Agency is also coordinating with Farm Production and Conservation Business Center and the Department on the multi-year data management efforts to improve transparency, data mining, intelligence dashboards, and program analysis. Equally, significant investments in the development and utilization of program dashboards and visualizations have been made by Farm Service Agency. These efforts are helping to increase transparency, augment analytics capacity and make data readily available to support important mission-focused decision-making.

Farm Service Agency has built a number of dashboards to provide visualizations for its major Farm Programs and Farm Loan Programs, such as Coronavirus Food Assistance Program 1, Coronavirus Food Assistance Program 2, Wildfires and Hurricanes Indemnity Program Plus, Dairy Margin Coverage, Agriculture Risk Coverage and Price Loss Coverage, Conservation Reserve Program, Farm Loan Program Direct Loan Portfolio, Farm Loan Program Loan Obligations, program payments, acreage reporting, etc. Nationwide administrative dashboards to view office workload, productivity, and the geographic servicing areas for Farm Service Agency leadership and managerial staff have also been developed throughout fiscal year 2022.

The Agency is planning to request Congressional funding for enhancing: 1) transactional program systems/software to quickly meet the implementation demands of pandemic, emergency, and disaster programs and 2) interface systems to allow data sharing and eliminate manual/duplicative entries and processes.

National Payment Eligibility and Payment Limitation training was provided at the National Training session held in Dallas TX.

In addition, Farm Service Agency completed an analysis of improper payment findings for the program. To address acreage reporting issues, Deputy Administrator for Farm Programs has created a task force who met in August 2023 to develop recommendations to inform a timeline of adoption. One of the
primary objectives of this task force is to address improper payment findings related to the acreage reporting process. The team reviewed policies and software enhancements to identify possible changes that would mitigate risks associated with improper payments. The task force will develop proposed solutions and training materials. The team will provide these recommendations to Deputy Administrator for Farm Programs by December 31, 2023.

Commodity Credit Corporation (CCC) Livestock Forage Disaster Program has established a baseline.

With the implementation of the current corrective actions and the planned corrective actions for the program, it is the agency’s anticipation that the projected reduction target will be less than the estimated future improper payment rate.

The program's current year improper payment and unknown payment rate of 13.66 % may or may not be the tolerable rate. The agency has not yet determined the tolerable rate for this program.

The agency does not have sufficient resources to add needed internal controls, human resources, and information systems to reduce the improper payment and unknown payments. The agency will continue to strategically take the necessary steps to strengthen internal control measures, establish uniform consistency for compliance processes, and improve accountability. A continuous evaluation system which monitors the effectiveness of internal controls is in place but is not sufficient to reduce improper payments rates. Lastly, agency will require key resources to continue its progression towards strengthening internal controls and addressing the inconsistencies with certain programs reporting more than the statutory improper payment threshold.

Livestock Forage Disaster Program does not have sufficient resources to add needed internal controls, human resources, and information systems to reduce the improper payment and unknown payments. Livestock Forage Disaster Program leverages the existing internal controls environment and accountability processes to provide reasonable assurances that internal controls are in place and operating effectively. A continuous evaluation system which monitors the effectiveness of internal controls is in place but is not sufficient to reduce improper payments rates.

The fiscal year 2024 President’s Budget and the fiscal year 2025 Department Estimates submitted to Office of Management and Budget does not include funding levels to support the required software enhancements to increase application controls. Due to budget constraints for the agency approved funding levels, the funding required to build automated internal controls within the existing systems is not included.

Incorrect acreage reporting has been a reoccurring finding for Livestock Forage Disaster Program. Accurate accounting can be complex when producers have multiple fields, and especially in multiple counties, or when determined animal units are converted to acres. While training has kept these findings from increasing, automation enhancements are needed to fully assure that administrative errors are mitigated, however funding has not been available. Specific national training has been conducted as recently as July 15-19, 2024. All trainings are recorded and posted on Deputy Administrator for Farm Program’s Livestock Forage Program Training site. Further, Safety Net Division holds monthly Livestock Forage Disaster Program trainings with State Office Livestock Forage Disaster Program specialists to discuss findings and address any questions. All calls are recorded and posted on Deputy Administrator for Farm Program’s Livestock Forage Disaster Program Training SharePoint site. These corrective actions are sufficient to mitigate the program’s $134.90 million of improper payment dollars related to statutory requirements not met.

The root cause of these improper payments was statutory requirements of program not met. Corrective actions such as training and awareness have had a positive impact, which is represented in a reduction in Livestock Forage Disaster Program’s Payment Integrity Information Act error rate in Fiscal Year 2024 compared to Fiscal Year 2023. Overall, Livestock Forage Disaster Program’s improper payment percentage has remained between 9-13 percent for the last three years, which included many pandemic and disaster related ad hoc programs which were being administered during this time with limited resources. These corrective actions are adequate to address the cause of the improper payments.

The root cause of these improper payments was statutory requirements of program not met. The agency has established various task forces that consist of State and county office specialists to discuss issues, findings, and suggest solutions relating to administrative errors in the failure to obtain the required supporting documentation and proper acreage reporting. The outcome was identifying needed software enhancements, developing training opportunities, and issuing policy updates in agency handbooks. These corrective actions are focused on the cause of the improper payments.

Actions taken to reduce Livestock Forage Disaster Program’s improper payment percentage have been effective. In August 2018. Farm Service Agency released a software update that integrated the Crop Acreage Reporting System software in the Livestock Forage Disaster Program application software. With this implementation, acres or animal units are now interfaced directly from producer acreage reports, which are a requirement for Livestock Forage Disaster Program, directly into the Livestock Forage Disaster Program application software. This replaced the manual entries and significantly mitigated errors of calculating the total of eligible acreage. In Fiscal Year 2021, Livestock Forage Disaster Program’s improper payment percentage decreased to 8 percent. Livestock Forage Disaster Program’s improper payment percentage has increased in two of the last three fiscal years in part due to increased participation in Livestock Forage Disaster Program, and a lack of funding for software enhancements.

Actions taken enhancing software to interface eligible acreage or animal units and establishing Livestock Forage Disaster Program monthly trainings with State Livestock Forage Disaster Program specialists, raising improper payment awareness. All actions have contributed to reducing Livestock Forage Disaster Program’s improper payment percentage. These corrective actions will be effectively implemented and prioritized within the agency to reduce improper payments.

Commodity Credit Corporation (CCC) Livestock Forage Disaster Program has established a baseline.

With the implementation of the current corrective actions and the planned corrective actions for the program, it is the agency’s anticipation that the projected reduction target will be less than the estimated future improper payment rate.

The program's current year improper payment and unknown payment rate of 12.9 % may or may not be the tolerable rate. The agency has not yet determined the tolerable rate for this program.

The agency’s target rate for Livestock Forage Disaster Program is to have an improper payment percentage below 10 percent, however this may not represent the definition of a “tolerable rate”. All corrective actions taken by the agency have been implemented with the goal to be within the 10 percent threshold.

A tolerable rate for Livestock Forage Disaster Program has not been established; however, the Agency is in the process of establishing additional internal controls for its permanent programs such as Livestock Forage Disaster Program. For example, Farm Service Agency is in the process of establishing a monitoring system to assure that county offices review payments before being issued. The system also has an accountability component to identify offices that struggle to disburse proper payments. Once implemented, Farm Service Agency will be in a position to determine a tolerable rate based on established data. Farm Service Agency will request Commodity Credit Corporation Section 4 and 11 funding during the Fiscal Year 2025 Commodity Credit Corporation budget request and Working Capital Fund request drills. Estimated funding requirements for system enhancement is $2 million.

In order to reduce Livestock Forage Disaster Program’s improper payments, system enhancements and training for staff is required; however, Farm Service Agency’s information technology budget is not adequately funded to implement the requested enhancements. Farm Service Agency will request Commodity Credit Corporation Section 4 and 11 funding during the Fiscal Year 2025 Commodity Credit Corporation budget request and Working Capital Fund request drills. Estimated funding requirements for system enhancement is $2 million.